Models of Regulatory Activity in Eu Countries: Comparative Analysis and Recommendations for Ukraine

The article provides a comparative analysis of the main models of regulatory activity established in the EU countries, namely, the Anglo-Saxon, continental, Scandinavian-consultative models, as well as the supranational model of “better regulation” at the EU level. The author focuses on the institutional, procedural and methodological peculiarities of drafting legal acts in different legal systems. Based on a comprehensive study of European practices, the author identifies the key elements that ensure high quality of the legislative process: professionalisation of drafters, mandatory impact assessment of regulatory acts (RIA), institutionalisation of legal technique standards, and broad stakeholder involvement in the development of policy decisions and the regulatory framework. The article also provides a critical analysis of the current state of regulatory drafting in Ukraine, identifying the main challenges that significantly affect its quality and stability, including dispersion of procedures, insufficient coordination between public authorities, weakness of impact assessment institutions, and imperfect linguistic and structural aspects of legislative texts. Based on the findings of the study, the author offers a number of practical recommendations for the implementation of elements of European models in the national legal system of Ukraine. In particular, these include the need to create a professional corps of legislative advisers, introduce mandatory impact assessment procedures, develop a single law on regulatory legal acts, and digitalise and ensure openness of the rulemaking process. The results of the study have theoretical and practical value for improving Ukraine’s regulatory drafting on the path to European integration, contributing to improving the quality of legislation, strengthening the rule of law, and the development of democratic governance.